ML20062N761
| ML20062N761 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 01/03/1994 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9401210067 | |
| Download: ML20062N761 (11) | |
Text
N Commonw:alth Edison e
L/ 1400 Opus Place v 7 Downers Grove. Illinois 60515
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January 3,1994 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attn: Document Control Desk
Subject:
Quad Cities Power Station Units 1 and 2; NRC Docket Number 50-254 and 50-265; NRC Inspection Report Numbers 50-254(265)/93024
Reference:
Geoffrey C. Wright letters to L. O. DelGeorge dated November 12,1993 and December 1,1993, transmitting Notice of Violation with Inspection Report 50-254/93024; 50-265/93024 Enclosed is Commonwealth Edison's response to the Notice of Violation (NOV) transmitted with the referenced letter. The attachment provides the t
response to your request for any actions planned regarding weaknesses in substation construction's documentation related to switchyard equipment preventive, predictive, and corrective maintenance.
The NOV cited three Severity Level IV violations; one violation with two examples regarding testing activities, one violation for procedure implementation, and one violation with three examples for failure to promptly identify corrective actions.
If there are any questions or comments concerning this letter, please refer
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them to Marcia Jackson, Regulatory Performance Administrator at (708) 663-7287 Respectfully, 7
140018 D. L. Farrar, Manager Nuclear Regulatory Services Attachment cc: J. Martin, Regional Administrator, RIII C. Patel, Project Manager, NRR T. Taylor, Senior Resident Inspector, Quad Cities
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i RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION ItEPORT 50-254(265)/93024 YK&ATION: 254 (265)/93024-02a During an NRC inspection conducted July 28-30, August 2-4, and August 9-20, 1993, violations of NRC requirements were identified. In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, the violations are listed below:
10 CFR 50, Appendix B, Criterion XI states, in part, that all testing required to demonstrate that structures, systems, and components will perform satiActorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
QAP 1500-17, " Post-Maintenance TestingNerification Procedure", Revision 4, required that post-maintenance tests be specified, performed and documented fbilowing maintenance activities.
l Contrary to the above, on April 26,1993, the licensee failed to specify the required post-maintenance testing associated with nuclear work request #Q99959 (Bus 22 -
l 4kV breakers) and testing was not performed (254/265-93024-2A(DRS)).
IEASON FOR THE VIOIJTION:
CECO acknowledges the violation. The reason for the violation is personnel error.
The individuals responsible for specifying and performing appropriate post-maintenance tests to ensure equipment will perform its design function failed to implement the requirements in QAP 1500-17.
i CORRECTIVE STEPS TAKERAND RESULTS ACHIEVED:
The requirements of QCAP 308-00, (formally QAP 1500-17) " Post Maintenance TestingNerification Procedure", have been reemphasized with the individuals involved. The Master Matrix for 4kV breakers, which is utilized to determine test requirements for PMTN's, was approved on May 3,1993. This Master Matrix requires that the breaker be cycled from the controlling station and verification that the associated equipment is energized.
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RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254(265)/03024 i'ORRECTIy_E STEPS TAKEN TO AVOID FURTIIER. VIOLATIONS:
Requirements of QCAP 308-00 will be reviewed with personnel responsible for the identification and performance of post maintenance tests to ensure their understanding of their responsibilities.
DATE WIIEN FULL COEPLIANCE WILL BE ACHIEVEDj Full compliance will be achieved by January 30,1994, when QCAP 308 - 00 will be reviewed with the responsible personnel (System Engineering, Maintenance and Operations).
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RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254(265)/03024 ylQlg i; 254 (265)/93024 02b Technical Specification Table 3.2-2, an operation analysis division (OAD) relay setting order, and procedure QCOADS 100-1, " Rock River Division OAD Under voltage Relay Calibration," Revision 0, required a setting of 87 volts
- 5% (82.65 to 91.35 volts) for the 4kV emergency bus under voltage relays.
Contrary to the above, as of March 18,1993, the licensee failed to implement the above design requirements and acceptance limits during testing of the 4kV buses 23-1 and 24-1 under voltage relays. The calibration data sheets used specified 83 volts t 5% (79 to 87 volts)(254/265-93024-02B(DRS)).
RIMSON FOB TILE VIOLATION:
CECO acknowledges the violation. The reason for the violation is personnel error.
A personnel error was made when the OAD Engineer responsible for the calibration of the under voltage relays failed to document on the calibration data sheet the allowable Technical Specification voltage range. The actual voltage range documented was for manufacturer tolerances, and not that required by Technical Specifications. Operational Analysis Department Procedure # 1 -
Protective Relays Calibration (OADMP-1) Table 2 states " Technical Specifications that impose stricter tolerances take precedence over the values listed in this acceptance criteria." While the acceptable voltage range documented on the data sheet was incorrect, the "as found" and "as left" relay calibration was evaluated by the OAD engineer at the time of the calibration, per procedure OADMP-1, to be within the Technical Specification range.
.C_ORRECTIVE ACTION TAKEN AND RESULTS ACHIEVIM; 1
The OAD engineer involved in the calibration was counseled on his error. Rock River Division OAD Under Voltage Relay Calibration Procedure (QCOADS 100-1) has been approved and incorporates instructions to ensure that Technical Specification under voltage and degraded voltage relays are calibrated to meet Technical Specification criteria.
SIEEfiTREN TO AVOID FURTHER VIOLATIONS:
Procedure QCOADS 100-1 includes sign off steps by the OAD engineer verifying that relays are within Technical Specification acceptance criteria. A SRO review of calibration data is conducted as well.
DATE WHEN FlLL COMPLIANCE WILL ACHIEVED Full compliance was achieved on August 20,1993, when procedure QCOADS 100-1 was approved.
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RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254(265)/93024
. VIOLATION: 254 (265)/93024-03 10 CFR 50, Appendix B, Criterion V states that activities afTecting quality shall be prescribed by documented instructions or procedures, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions or procedures.
Nuclear Operations Directive (NOD) OP.16, "DC Ground Action Requirements,"
dated October 1,1989, provided action requirements for plant operation with electrical grounds on safety-related de systems.
Contrary to the above, from October 1,1989 to August 20,1993, the licensee failed to address NOD ground requirements as specified in the NOD and subsequent plant procedures (254/26543024-03(DRS)).
REASON FOll TIIE VIOLATIOM CECO acknowledges the violation. Various provisions of the NOD are not implemented by Station procedures due to Management oversight. The NOD defined three levels of DC grounds (Level I, II, and III) but plant procedures do not refer to the levels in these terms and what operator actions are required. The NOD also refers to identification of new grounds masked by other grounds and the preparation of a 'DC System Ground Report.' The information identified in the DC System Ground Report is typically recorded in the Shift Engineer Log for grounds of Levels II and III magnitudes. However, there is no proceduralized DC ground report issued at the Station to comply with this provision. The 'DC System Ground Report Form' in the NOD stated that "If the ground is a Level III and cannot be corrected within 3 days ofits occurrence, a copy of this data form must be sent to general office (Nuclear Engineering and the appropriate Nuclear Operations General Manager) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This requirement is not implemented by Station procedures. The NOD included a table indicating voltage / resistance calculations and response actions at different CECO nuclear power plants. The contents of this table are not included in plant procedures.
CORIlFSTIVE STEPS TAKEN AND RESULTS ACHIEVED:
Station procedures, QOP 6900-4,5,6, and 7 address portions of NOD OP.16.
Specifically, the magnitude ranges of ground level II and III are identified in these procedures which correspond with ranges identified in the NOD. QOP 6900-4,5,6, and 7 are used to isolate grounds from the DC systems. QOS 005-S12 and S18 are used to record ground readings once a shift. This combination of procedures is used in identifying new grounds with an existing ground isolated. In addition, QCOP 6900-19 has been written and is in use for documenting intermittent grounds as directed under section 5.6 of the NOD.
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RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254(265)/93024 COJ1RECTIYILSTEES TAKEN TO AVOIDJURTIIER VIOLATIONS; The NOD-OP.16 actions that are not currently implemented through station procedures will be reviewed by Quad Cities management for applicability and incorporated into station procedures. The selected actions, or more conservative substitutes, will then be incorporated into station procedures to enhance the existing DC ground policies. These procedures will supersede NOD-OP.16.
DA'E WII@LELLL COMPLIANCE _WILLILE ACHIEVED:
Full compliance with the above corrective steps will be achieved by April 30,1994, when the NOD requirements will have been reviewed and incorporated as necessary into station procedures.
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RESPONSE TO NOTICE OF VIOLATION -
NRC INSPECTION REPORT 50-254(265)/93024
. VIOLATION: 254 (265)/93024-04a 10 CFR 50, Appendix B, Criterion XVI states, in part, measures shall be established to assure that conditions adverse to quality, such as, failures,
- malfunctions, deficiencies, deviations, defective material and equipment, and-nonconformances are promptly identified and corrected.
Procedure QCAP 2300-6, " Station Commitment and Action Item Tracking,"
Revision 0, required that operating experience, such as, General Electric's service infbrmation letters (SILS) be evaluated within 90 days.
Contrary to the above, prior to August 20,1993, the licensee failed to promptly evaluate / identify appropriate corrective actions for applicable SILs (254/265-93024-04A(DRS)).
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HEASON FOR THE VIOLATION:
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CECO acxnowledges and agrees with the violation. The root ca.use of the failure to j
review the above mentioned SILs in the required 90-day time frame is ineffective management oversight.
.CDRilFCTIVE STEPS TAKEN AND RESULTS ACHIEVED _;
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Resources have been directed to the SIL program and an action plan has been i
developed to review all SILs. This review identified 72 Sils determined to be potentially important to safety for which responses could not be found. Of these j
72, a review has been initiated for 54, and 18 are considered not applicable.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS:
A program will be developed to allow the OPEX Administrator to review OPEX t
item status which includes SILs, SOERs, Generic Letters, etc. and will notify line
.i management of this status on a monthly basis. This program will be implemented
'I by March 31,1994.
DATE WHEN FULL COMPL1ANCE WILL BE ACHIEVED:
Full compliance will be achieved by May 31,1994 when the remaining 54 SILs will be reviewed.
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V RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50 254(265)/93024 YIOIATION: 254 (265)/93024-04b Contrary to the above, from Novamber 30,1991, to August 20,1993, the licensee failed to complete corrective action inspections to identify / replace defective SBM switches on safety related and important to safety 4kV breakers (254/265-93024-04B(DRS)).
REASON FOR THE VIOLATION:
CECO acknowledges the violation. The reason for the violation is an inadequate review of a procedure change. Corrective action inspections were not completed on 4kV breaker SBM switches per vendor recommendations. Vendor inspection criteria addressing failure of SBM control switches on 4kV breakers manufactured during August through October 1982, was incorporated into procedure QEPM 200-1, rev 3., but was not referenced to the originating document. A subsequent revision to the procedure inadvertently removed the inspection criteria prior to the completion of the SBM switch inspection activity.
COIULILCTIVE STIEPS TAKEN AND RESUllrS ACIHEVED:
Revisions to QCEPM 200-1 (Inspection and Maintenance of 4kV Horizontal Circuit Breakers Type 4.76-250) and QCEPM 200-3 (Inspection and Maintenance of 4kV Vertical Circuit Breakers Type 4.16-350) are in progress to incorporate the vendor SBM switch inspection criteria and reference back to the originating document.
All unit 1 and 2 vertical 4kV breaker cubiclee and vertical 4kV breakers on site have been inspected. Of the horizontal 4kV breakers and cubicles,22 of the 89 breakers and 8 of 90 cubicles have been inspected.
CDRI1ECTIVE STEPS TAKEN TO AVOID FURTHER VIOIATIONS:
Communication will be provided to individuals responsible for writing and revising procedures, this communication will reiterate the need to reference requirements to the originating document. Communication will also be provided to individuals responsible for the technical review of procedures to ensure any deletion or revision of statements are correct. The Writer's Guide will be amended to require ehall versus should statements, and will be reviewed and revised as necessary to address effectiveness.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:.
QCEPM 200-1 and QCEPM 200-3 are scheduled to be revised by January 31, 1994. Inspections of Unit 1 and Unit 2 4kV SBM switches are scheduled to be completed at the end of their respective refuel outages in 1994. Communications reiterating expectations ofindividuals, who write and review procedures, will be completed by March 31,1994.
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ILESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPOILT 50-254(265)/93024 VIOLATION: 254 (265)/93024-04c Contrary to the above, from December 16,1991, to August 20,1993, a number of broken / damaged parts were identified that indicated improper handling of safety-related and important to safety 4kV breakers. Improper handling of 4kV breakers had previously been recorded by licensee personnel, but no corrective action were taken to resolve this condition (254/265-93024-04C(DRS)).
These violations represent a Severity Level IV problem (Supplement-1).
HEASON FO_Lt THE VIDLATION_;
CECO acknowledges the violation. Quad Cities Station has experienced failures on i
4kV horizontal breakers which could be the result of rough handling. In moving these large breakers in and out of the cubicles, secondary disconnects have been damaged from the breaker bumping the cubicle housing. If racked into position incorrectly, auxiliary linkages can be damaged. In one instance, rough handling of a breaker during racking was witnessed by the System Engineer and entered into his daily log. Based on this observation discussions on proper racking were held at the time by an Operating Engineer with operations personnel. While it was believed this discussion would resolve the improper racking, no formal documentation of this action was made.
CDRRECTIVE STFAS_TAKEN ANIUtJESULTS ACHEVED:
The work history on 4kV breakers back through 1988 has been reviewed. Based on this review the number of failures or repairs on auxiliary linkages and secondary disconnects indicated the need to improve operator handling of these breakers. This information has been used to revise training lesson plans on breaker handling / racking and was presented to operators in tailgate training by the system engineer and operating engineer.
Also, since the time of this event, an improved process has been established to document problems of the nature observed by the System Engineer. A Problem Identification Form (PIF) was created as a method to notify management of performance deficiencies. The System Engineers have been instructed on how to use the PlF process. No abuses of 4kV breakers have been identified by the System Engineer since the time of the finding.
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RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-254(265)/03024 COItBECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS:
Retraining with the revised lesson plan will be conducted as part of operator crew training during the first quarter of 1994. These actions to improve operator handling of 4kV breakers should prevent recurrence.
QCAP 200-1, " Conduct of Operations", is being submitted as a new procedure to replace QAP 300 - 2, " Conduct of Operations". Operating Department expectations with respect to the improper handling of plant equipment have been incorporated into this new procedure to ensure these expectations are clearly delineated. In addition, these expectations have been incorporated into the Non-Licensed Operator Training Program to ensure the operators understand the importance ofidentifying deficient or degraded plant equipment, as well as the importance of promptly communicating these deficiencies to their supervision so as to allow for timely corrective action implementation.
DATE WIIEN FULL COMPLIANCE WILIE ACHIEVED:
Full compliance will be achieved by March 31,1994, with the completion of operator crew training.
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NITACHMENT NRC INSPECTION REPORT 50-254(265)/93024 In response to your cover letter regarding weaknesses in Substation Construction's (SSC) documentation related to switchyard activities, the following information is provided.
SSC's process for recording and maintaining maintenance history for switchyard activities was deficient. This condition had been previously identified by SSC Management and resulted in the scheduled replacement of the existing tracking system which is currently in progress. SSC Management has taken interim steps to address improvement in OCB maintenance. Specific skill training about OCB maintenance by Rock River Substation Construction mechanics has been completed. SSC Regional Managers, Work Planners, and Maintenance Planners have been made aware of the Quad Cities DCB issue. OCB Interrupter assembly cotter pins are being inspected as part of the regular maintenance cycle.
i Task oriented checklists will be developed and issued for trial uce at nuclear sites.
Review and approval of the specific checklists are scheduled for completion in the first quarter of 1994. Subsequent to the approval of the checklist, use by field personnel during routine maintenance will become mandatory. The revised checklist will be incorporated into the new Electrical Inspection and Maintenance (EFIM) tracking system which will replace the existing maintenance tracking system by the end of the first quarter of 1994.
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